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قوانین ضد پولشویی و احراز هویت | سیاست AML و KYC

Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy – bet365info.org 🔒

Last updated: 25 October 2025

This page explains the Anti-Money Laundering and Know Your Customer policy used by bet365info.org. Our goal is simple: to help keep the platform safer for users, reduce the risk of financial crime, and make sure payment-related activity is handled with proper checks and accountability. Because betting and online payments involve real money, we take verification, monitoring, privacy, and responsible use seriously. ✅

📌 Scope, Purpose, and Applicability

This policy applies to all areas of bet365info.org where user accounts, payments, identity checks, deposits, withdrawals, user-to-user transfers, promotional credits, support requests, or dispute reviews may be involved. It also applies to team members, contractors, payment partners, technical providers, and any service provider that helps us deliver or support these services.

🧭 Regulatory Alignment & Best-Practice References

  • FATF Recommendations covering a risk-based AML/CFT approach, customer due diligence, enhanced due diligence, ongoing monitoring, reporting, and record retention.
  • Directive (EU) 2015/849 and Directive (EU) 2018/843 (AMLD4/AMLD5), which set out key AML/CFT expectations.
  • Regulation (EU) 2015/847 regarding information that should accompany transfers of funds.
  • Relevant national laws, sanctions requirements, regulatory guidance, and payment partner obligations based on user location and transaction activity.
  • Data protection principles aligned with GDPR-style standards, including privacy, security, purpose limitation, and data minimization.

🧾 Definitions

  • Money Laundering (ML): Hiding, moving, converting, or disguising the source of money or property that may come from criminal activity, including helping someone avoid legal consequences.
  • Customer Due Diligence (CDD/KYC): The process of identifying users, verifying their details, understanding the purpose of the relationship, and monitoring activity over time.
  • Enhanced Due Diligence (EDD): Additional checks used when a user, jurisdiction, payment method, product, or behavior presents a higher level of risk.
  • Source of Funds (SoF) / Source of Wealth (SoW): Documents or information that help confirm where deposited money or overall wealth legitimately comes from.
  • Suspicious Transaction/Activity Report (STR/SAR): A formal report submitted to the relevant Financial Intelligence Unit (FIU) when money laundering or terrorist financing is suspected.

🏛️ Governance & Accountability

  • Senior Management approves this policy, sets expectations from the top, assigns resources, and reviews whether controls are working as intended.
  • AML Compliance Officer (AMLCO) designs and maintains AML controls, oversees monitoring, reviews alerts, escalates serious cases, and communicates with competent authorities where required.
  • First Line (Operations & Support) carries out CDD/EDD steps, applies payment rules, checks user information, and reports unusual activity internally.
  • Internal Audit performs independent reviews, tests the effectiveness of controls, and recommends improvements when gaps are found.

🛠️ Policy Maintenance & Change Control

When a material change is needed, it is reviewed through a documented risk impact assessment and approved by Senior Management and the AMLCO. Previous versions are kept in archive so decisions and updates can be traced during audits or internal reviews.

🧩 Risk-Based Approach (RBA) & EWRA

bet365info.org conducts an Enterprise-Wide Risk Assessment (EWRA) at least once a year. This assessment looks at risks across products, payment channels, user profiles, geographic exposure, transaction patterns, sanctions concerns, and new financial crime methods. The results help define verification thresholds, monitoring rules, EDD triggers, and the frequency of reviews.

🪪 Tiered Customer Verification (KYC)

Account verification is handled in tiers. Depending on the user’s activity, some actions—especially withdrawals—may be paused until the required verification level is completed.

  • Tier 1 – Basic Profile (required before any withdrawal)
    • Full name, date of birth, gender, nationality, country of usual residence, and full residential address.
    • Automated database checks may be used. If information cannot be confirmed or does not match, proof of address may be requested.
  • Tier 2 – Advanced ID Verification
    • Required when cumulative deposits or withdrawals reach 2,000 (USD/EUR or equivalent).
    • A valid government-issued ID photographed next to a random 6-digit code handwritten by the user, plus a live selfie for identity matching.
    • If electronic verification is unsuccessful, a recent proof of address may be required, such as a utility bill, bank statement, or official letter issued within the last 3 months. The full name and address must be visible, all four corners must appear, and the text must be readable.
  • Tier 3 – Source of Funds / Source of Wealth (SoF/SoW)
    • Required when cumulative deposits or withdrawals reach 5,000, or when peer-to-peer transfers reach 3,000.
    • Accepted SoF/SoW documents may include employment payslips, audited business accounts, investment statements, inheritance documents, tax filings, or notarized evidence of asset sales.

🌍 Geographic Risk Categorization

  • Low Risk: Standard verification tiers and thresholds apply as described in this policy.
  • Medium Risk: Lower thresholds may apply, including 1,000 for Tier 2 and 2,500 for Tier 3. Crypto-to-fiat activity may also be treated as medium risk depending on the context.
  • High Risk: Access to services may be limited or prohibited. Jurisdiction lists are reviewed against sanctions, regulatory warnings, and partner requirements.

💳 Payment Method Controls

  • The same method used for a deposit should be used for withdrawal at least up to the deposited amount, helping reduce circular-flow and laundering risks.
  • Third-party cards, wallets, or bank accounts are not allowed. The payment account name must match the verified user’s name.
  • Breaking deposits or withdrawals into smaller amounts to avoid thresholds is treated as a red flag and may lead to EDD, account limits, or closure.

🔎 Ongoing Monitoring & Three Lines of Control

  • First Line: We work with reputable payment service providers that apply AML/KYC controls during onboarding and transaction processing.
  • Second Line: The AMLCO oversees rule-based and machine-assisted monitoring. Red flags may include quick deposit-withdrawal cycles, inconsistent account behavior, frequent currency switching, account-takeover signals, or links to high-risk locations.
  • Third Line: Suspicious or high-risk cases are reviewed manually. STR/SAR reports are filed with the competent FIU when required by law.

📈 Control Thresholds at a Glance

Control Layer Trigger Required Actions
CDD Tier 1 Account creation / before first withdrawal Profile details plus automated checks; proof of address if required
CDD Tier 2 Deposit or withdrawal ≥ 2,000 Government ID, handwritten 6-digit code, selfie, and PoA if e-checks fail
EDD Tier 3 Deposit/withdrawal ≥ 5,000 or P2P ≥ 3,000 SoF/SoW evidence, enhanced screening, and manual review
Monitoring All customers Rules and ML models, sanctions checks, case management, and STR/SAR where applicable

🧩 Acceptable SoF/SoW Examples

  • Employment income, such as recent payslips, an HR letter, or tax statements.
  • Business ownership, including audited accounts or corporate registry extracts.
  • Investments, such as brokerage statements, dividend records, or proof of asset liquidation.
  • Inheritance or gifts, including probate documents, notarized deeds, or bank confirmations.

🚨 Detection, Escalation, and STR/SAR

  • Staff must report unusual, inconsistent, or suspicious activity to the AML team promptly through secure internal channels.
  • The AML team reviews alerts, records the reasoning behind decisions, and files an STR/SAR with the relevant FIU where the law requires it.
  • “Tipping-off” is prohibited. Users are not informed about STR/SAR submissions when the law restricts such disclosure.

🧰 Procedures & Playbooks

Operational playbooks turn this policy into practical step-by-step procedures, including minimum CDD standards, sanctions screening, EDD triggers, case escalation, account restrictions, and user communication templates. To reduce circular fund movement, first withdrawals may require transactional activity of at least 70% of deposited funds.

🧾 Record-Keeping

  • KYC records are kept for at least 10 years after the business relationship ends.
  • Transaction records are kept for at least 10 years after execution or termination, whichever happens later.
  • Records are protected with secure storage, encryption at rest and in transit, and a mix of online and offline safeguards.

🧑‍🏫 Training & Awareness

  • New team members receive mandatory AML onboarding, while finance, risk, operations, and support teams complete periodic refresher training.
  • Training includes real-world typologies such as smurfing, mule accounts, synthetic identities, account takeover, and crypto on/off-ramp risks.
  • Training quality is monitored through KPIs, quality checks, audit results, and follow-up improvement actions.

🧪 Internal Audit & Continuous Improvement

  • Internal Audit regularly reviews AML controls, data quality, alert handling, and the timeliness of case reviews.
  • Metrics such as false-positive rates, case turnaround time, escalation quality, and post-investigation actions are used to improve the control framework.

🧱 Data Protection & Privacy 🔐

  • We collect only the information needed for lawful AML/KYC checks and service delivery. User data is not sold.
  • Information may be shared only where required by law, by competent authorities, or when necessary to prevent or detect financial crime.
  • We respect applicable privacy rights, including access, correction, restriction, and objection, subject to legal and compliance obligations.

🚫 Zero-Tolerance for Violations

  • Accounts connected to forged documents, stolen payment instruments, account takeover, fraud, or unexplained fund flows may be restricted, suspended, or closed.
  • Confirmed money laundering, terrorist financing, or fraud may be reported to competent authorities without prior notice, where permitted or required by law.

📫 Contact

If you have questions about this AML/KYC Policy, want to exercise your privacy rights, or need to report suspicious activity, please contact us through the “Contact Us” page on bet365info.org. 💬

⚠️ Compliance Notice

Using bet365info.org means you accept this AML/KYC Policy. If requested documents are not provided, or if verification cannot be completed, withdrawals may be delayed, transactions may be rejected, and account access may be restricted. We may update this document from time to time to reflect regulatory changes, supervisory expectations, payment partner requirements, and recognized best practices.

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